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The foreign tax credit you are allowed for each class of foreign income is limited to the Australian tax payable on that class of income. Therefore, you first must work out the Australian tax payable.

To do this, multiply your average rate of Australian tax by your adjusted net foreign income. Deduct any rebates which apply to that income - apart from a rebate under an Act fixing the rates of income tax or under an Act imposing income tax. Expressed as a formula, the calculation is as follows:

ATP = AR X ANFI

ATP

Australian tax payable

AR

average rate of Australian tax

ANFI

adjusted net foreign income

How is the average rate of Australian tax worked out?

The average rate of Australian tax (AR) is worked out by dividing the gross tax on your taxable income less certain rebates by your taxable income. Expressed as a formula, the calculation is as follows:

AR =

gross tax + Medicare levy - rebatestaxable income

For this calculation, deduct concessional, zone or overseas service rebates.

What is the adjusted net foreign income?

The adjusted net foreign income is your net foreign income adjusted for apportionable deductions. Apportionable deductions are deductions of a concessional nature that do not relate directly to income producing activities - for example, gifts.

Net foreign income is your gross assessable foreign income less:

allowable deductions relating exclusively to your foreign income

any domestic loss carried forward that you have elected to use against your foreign income

deductions allowed as being appropriately related to your foreign income.

How is adjusted net foreign income determined?

Your adjusted net foreign income is determined as follows:

If your net foreign income exceeds the sum of your taxable income plus apportionable deductions, your adjusted net foreign income will equal your taxable income

If your net foreign income consists of two or more classes of income - that is, quarantining applies - and your combined net foreign income from all classes is more than the sum of your taxable income plus apportionable deductions, your adjusted net foreign income (ANFI) for each class will equal your taxable income. This is divided proportionately, as shown in Example 2, into:

ANFI - passive income

ANFI - offshore banking income

ANFI - lump sum payments assessable under section 27CAA

ANFI - other income

In any other case, your adjusted net foreign income is your net foreign income multiplied by your taxable income divided by the total of your taxable income and apportionable deductions. Expressed as a formula, the calculation is as follows:

ANFI = NFI x

TITI + AD

ANFI

adjusted net foreign income

NFI

net foreign income of a class

TI

taxable income

AD

apportionable deductions

Example 2Working out adjusted net foreign income

An individual has:

$

domestic source income

7,000

allowable deductions from domestic source income

10,000

net passive foreign income

2,000

net other foreign income

5,000

apportionable deductions

100

Taxable income($7,000 - $10,000 + $2,000 + $5,000 - $100)

3,900

Taxable income plus apportionable deductions($3,900 + $100)

4,000

Net foreign income ($2,000 + $5,000)

7,000

The net foreign income is greater than the taxable income and apportionable deductions. Therefore, the adjusted net foreign income is taken to equal taxable income. As there are two classes of foreign income, it is necessary to apportion the adjusted net foreign income into the relevant classes - that is, passive income and other income.

The taxpayer's passive income is 2/7 and other income 5/7 of the combined net foreign income. The adjusted net foreign income for each class is as follows:

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